12/09/25
Costa Rica is often described as a hub for online gambling operators. But does it actually issue a gambling license - or is it a legal workaround? This article explains the true legal framework, the practical route used by operators, and the growing risks and obligations under Costa Rican and international law.
📜 Legal Framework and Official Position
Costa Rica does not operate a dedicated online gambling licensing regime. Unlike Malta or the UK, there is no specialist gambling regulator. The Gambling Law of 1922 restricts games of chance for Costa Rican residents, while the Junta de Protección Social (JPS) oversees state lotteries and other permitted domestic games.
Instead, international operators establish their presence through:
• Incorporation of a Costa Rican company (S.A. or S.R.L.)
• Tax registration with the Dirección General de Tributación
• Municipal authorisation for business activities such as data processing
• A legal opinion from local counsel confirming operations are directed only at non-residents
Operators must not serve Costa Rican citizens or residents. Compliance is generally ensured through geo-blocking and contractual restrictions.
⚖️ Compliance, AML and Taxation
Although there is no gaming regulator, Costa Rica imposes several legal obligations:
• Anti-Money Laundering (AML): Law No. 7786 (1998), reinforced by Law No. 8204 (2002), requires companies to implement AML/KYC procedures. Oversight falls under SUGEF, and Costa Rica is subject to GAFILAT/FATF reviews. A 2024 Enhanced Follow-Up Report noted improvements, but also ongoing weaknesses.
• Crypto/VASP Bill: In 2025, Costa Rica advanced a bill to bring virtual asset service providers (VASPs) under SUGEF supervision, introducing registration and AML duties. This could directly affect operators accepting crypto in gambling contexts.
• Tax: Costa Rica applies a territorial tax system. Income sourced abroad is generally exempt from local corporate tax. However, companies must be properly registered for tax purposes and maintain accurate records. The practical outcome depends on the structure and place of management, so legal tax advice is essential.
• Local restrictions: Offering gambling services to residents risks enforcement under the 1922 law and municipal penalties.
🌍 Comparison with Other Jurisdictions
Costa Rica differs fundamentally from regulated markets such as Malta, the Isle of Man, or the UK:
• No regulator vets beneficial ownership, financial stability, or technical standards
• No mandatory audits, fairness testing, or dispute-resolution frameworks
• No authority dedicated to consumer protection or responsible gambling
These gaps mean the jurisdiction is fast and inexpensive, but its recognition is limited. Banks, payment processors, and affiliates increasingly require a license from a recognised regulator. As a result, Costa Rica is suitable only for businesses targeting unregulated or grey markets — not those seeking access to fully regulated markets.
🏢 Practical Use Cases
In practice, Costa Rican operators:
• Register companies locally and obtain a “data processing” commercial licence
• Host platforms offshore but process data or services through Costa Rica
• Rely on legal opinions to demonstrate local compliance
• Implement AML/KYC frameworks to satisfy banking partners
Industry reporting in 2024–2025 shows growing pressure on these operators. International partners demand stricter due diligence, transparency, and compliance even without a domestic regulator. The pending VASPs bill illustrates a trend towards greater scrutiny, particularly where digital assets are used in gaming.
📝 Conclusion
Costa Rica is not a “licensed gaming jurisdiction” in the traditional sense. Instead, operators rely on corporate formation, municipal permits, and legal opinions — a workaround rather than a formal regulatory regime.
The benefits are speed and low cost. The risks are significant: lack of international recognition, restrictions on serving locals, increasing AML/CFT obligations, and limited acceptance by payment providers.
If you are considering Costa Rica for your online gambling operations, expert legal guidance is essential. NUR Legal advises on company formation, AML/KYC compliance, and structuring operations to meet both local and international requirements. Contact us for tailored legal services.
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Emil Korpinen